ML20134N865

Insp Rept 70-1201/97-01 on 970113-17.No Violations Noted. Major Areas Inspected:Radiological Controls,Environmental Protection & Waste Mgt

ML20134N865
Person / Time
Site:	07001201
Issue date:	02/14/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134N861	List: ML20134N858 ML20134N865
References
70-1201-97-01, 70-1201-97-1, NUDOCS 9702250013
Download: ML20134N865 (21)

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l l EXECUTIVE

SUMMARY

B&W Fuel Company NRC Inspection Report 70 1201/97-01 The primary focus of this unannounced inspection was the observation and evaluation of the licensee's radiation protection, environmental protection, I

and waste management programs. The report covers a one week period and includes the results of inspection efforts of two regional fuel facility inspectors.

l Based upon the results of this inspection, the licensee's radiological control environmental protection, and waste management programs were acceptable. The inspection identified the following aspects of the program as outlined below:

l RADIOLOGICAL CONTROLS l

e Observed radiological work and exposure control practices were acceptable.

, e All exposures were significantly less than 10 CFR 20 limits.

e The licensee's system for the identification of health physics problems was adequate.

! e The scope of the inde>endent audits was insufficient for providing a timely verification t1at essential program elements were adequate and implemented in accordance with requirements.

l e The implementation of administrative controls for the instrument accountability system (location and calibration documentation) was fully executed.

Environmental Protection l e The licensee's sampling program was consistent with the requirements in Section 5.2 of the license application and licensee procedures.

e Environmental sample anelysis anomalies were noted in the soil, l sediment, and vegetation sample results collected in 1996.

1 e The licensee's quality control program for environmental analytical measurements was less than adequate in that there was no formalized procedure to 3rovide guidance for im)lementing a quality assurance program for t1e licensee's vendor la> oratory. I Waste Manaaement e The licensee had implemented an effective program to monitor and control gaseous radioactive effluents and to maintain the radioactivity released in those effluents to quantities less than the license application limit i and concentrations which were below the limits specified in 10 CFR 20 '

for release of radioactive material to unrestricted areas.

9702250013 970214 PDR ADOCK 07001201 C PDR

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e There were a number of inconsistencies noted in the procedures pertaining to notifications and reporting.

e The licensee's controls and procedures for the solid waste management program were acceptable and capable of accomplishing its safety objectives.

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.U. S. NUCLEAR REGULATORY COMMISSION  !

REGION II  ;

4 Docket No.: 70 1201

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. License No.: SNM 1168 i l

1 Report No.: 70 1201/97 01 4

i Licensee: B&W Fuel Company d/b/a Framatome Cogema Fuels Facility: Commercial Nuclear Fuel Plant

$ Location: Lynchburg, VA

- l l Dates: January 13 17, 1997 a

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Inspectors: W. B. Gloersen, Senior Radiation Specialist  !

A. Gooden, Radiation Specialist l I

Approved by: E. J. McAlpine, Chief  !

Fuel Facilities Branch Division of Nuclear Materials Safety i i

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II. Radioloaical Controls i

A. Radiation Protection (83822) (R1) I

1. Radiation Protection Proaram Eauipment (R1.03)

a. Inspection Scoce The inspector toured the Service Equipment Refurbishment Facilities (SERF), Fuel Manufacturing, and the Whole Body Counting i Trailer to verify that radiation protection equipment was i calibrated and operational. The inspector also toured the survey  ;

instrument storage and future calibration room to review the  !

licensee's accountability controls for identifying the location of instruments and ensuring the operability and periodic i

calibrations.

b. Observations and Findinas  !

, Survey and frisking instruments were checked at various locations  ;

(SERF 4, Pellet Loading Room (PLR), and the health physics office) for o>erability and current calibration stickers. All instruments were )attery checked and several were checked for response to a radioactive source. Fixed air sampling locations were examined 1 and samplers were found operational and flow rates were within set points. The inspector did not identify any concerns with

, inoperable instruments and equipment. Lapel air samplers were worn appropriately and properly handled to ensure the representativeness of samples being collected. Workers were also observed recording the required data for use in estimating and assigning dose.

In response to documentation control for instrument calibration and/or maintenance, the inspector requested documentation in support of instrument calibrations for randomly selected survey instruments. No problems were noted. The inspector reviewed the licensee's vendor work orders for verification that instruments and self-reading pocket dosimeters (SRDs) had been calibrated.

Since the last inspection of this area, the licensee had implemented a manual tracking program that made use of a card filing system containing the relevant information (e.g. instrument calibration date, date due, and the instrument identification and location). The inspector also noted that the equipment storage facility contained shelves which were labeled for arranging survey instruments based on the equipment status (e.g. calibrated, out of service, etc.).

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2 l i l c. Conclus' ions

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Based on the response of instruments and calibration dates, the .

administrative controls appeared to be effective in ensuring that >

4 instruments were operable and calibrated at the required frequency ,

in accordance with license requirements and procedures.

i The administrative controls and improvements made to the licensee's instrument filing / storage system were ade

ensuring that instruments were properly maintained, quate for calibrated.

l and inventoried.

! 2. External Exoosure Control (R1.04)

a. Inspection Scope i

/ The inspector reviewed Calendar Year (CY) 1995 data and i thermoluminescent. dosimeters (TLDs) exposure results for third quarter 1996, and estimated results for the fourth quarter 19%,

! to determine if exposures were .in compliance with 10 CFR Part 20 4 limits.

b. Observations and Findinas l

i The inspector reviewed documentation and discussed with a licensee l representative CY 95 exposures and personnel exposures for 1996 as i s of September 30, 1996. According to licensee documentation and an l L interview with a member of the licensee's staff, TLDs were issued l

!- on a monthly basis to employees working in SERF areas or other

! work areas where exposures were likely to vary from job to job, or i from day to day. External exposures as obtained via TLDs disclosed  !

j no exposures exceeded 10 percent of the total exposure limit for- -)

the CY-(500 millirem (mrem)). According to the documentation, the  ;

l- maximum Deep Dose Equivalent (DDE) was 396 mrem for 1995 assigned to an individual working in Bundle Assembly. Although the fourth  !

quarter 1996 TLD data was unavailable, as of September 30, 1996, i the maximum DDE was 296 mrem assigned to an individual working in i Field Services. The next highest (279 mrem) was assigned to a i worker in the PLR. '

Regarding extremity exposures, the inspector noted that select i personnel requiring monitoring were provided ring badge dosimetry. I' The highest ex msure for 1995 was 4.598 rems assigned to an individual wor (ing in PLR. According to the current monitoring results the maximum assigned exposure was 2.774 rems, and the next highest was 2.451 rems. Both individuals worked in the PLR. The maximum estimated exposure to the lens of the eye (Lens Dose Equivalent (LDE)) was 605 mrem assigned to a PLR worker.

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c. Conclusions Based on the records reviewed and interviews, the inspector determined that the licensee's external exposure control program was adequate for evaluating and monitoring. personnel exposures.

The inspector also noted that all assigned exposures were well below regulatory limits,

3. Internal Exoosure Control (R1.05)

a. Inspection Scope I

The inspector reviewed personal air sam) ling results for CY 95, i and for the period January through Octo>er 1996, to determine if '

exposures were in compliance with 10 CFR 20 limits,

b. Observations and Findinos Internal ex sures were assigned to personnel based on-lapel air sample resu s. In addition to the air sampling program, employees that were assigned to )otentially contaminated and/or airborne areas )articipated in t1e bioassay program for exposure verification. :or 1995, the maximum assigned Total Effective Dose Equivalent (TEDE) was 1.438 rems and was assigned to an individual  ;

in the PLR. The maximum assigned TEDE for CY 1996 based on data l as of September 30 and estimated dose for the remainder of 1996, was 880 mrem..This individual- also was assigned the highest Committed Effective Dose Equivalent (CEDE) of 753 mrem and worked in PLR. The maximum assigned Commited Dose Equivalent (CDE) during 1996 was 6.275 rems assigned to a PLR worker.

c. Conclusions Based on the records review and interviews, the inspector determined that the licensee's internal exposure control program was adequate for. evaluating and monitoring personnel exposures.

All assigned exposures were less than regulatory limits. Workers in PLR continued to be assigned the maximum internal dose.

4. Surveys (R1.08)

a. Inspection Scope The inspector verified that surveys were performed daily to determine if contamination limits were exceeded.

b. Observations and Findinas The inspector observed Health and Safety personnel conducting smear surveys and direct radiation measurements within the SERF 4 facility to determine if surveys were in accordance with procedures and action limits. The inspector noted that the survey 5

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was effective in the identification of changes in radiation level resulting from equipment movement and/or changes in stored i equipment inventory. The inspector observed an area survey within '

the SERF 4 facility performed on January 15, 1997, which detected an area radiation level change from the previous survey and

required further evaluation. Subsequently, the technician- l determined that the maximum direct radiation reading was )

80 mrem /hr and was emanating from equipment that was recently returned from field service operations. In response, actions were

taken in accordance with procedures for smearing, bagging, and labeling based on action levels.

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In addition to the above observation, data sheets for daily and i

quarterly radiological. surveys covering the period of January -

December 1996 were reviewed for selected areas, The documentation I for randomly selected areas disclosed that the surveys were

wrformed at the required frequency in accordance with procedures.

r urther, documentation showed that in the event area smear results i exceeded the action limits, actions were taken to decontaminate

area of smear to acceptable limits.

l C. Conclusions Based on performance in the area of collecting and documentation i of SERF 4 survey results, the inspector determined that the i licensee's survey program was adequate for identifying the presence of contamination, and survey procedures provided actions for ensuring that contamination was controlled. i

5. Imolementation of ALARA Prooram (R1.10)

a. InsoectiQD_S_ CODE The inspector reviewed the training program to determine if facility workers were informed of ALARA commitments and how radiation protection principles may help minimize the risk to radiation. In addition, the program for ALARA committee recommendations was assessed.

b. Observations and Findinas Based on procedural review and discussion with licensee representatives, all employees working with radioactive materials or involved with any activity directly related to fuel fabrication, or requiring access to radiation controlled areas (RCAs), were required to annually complete training. In most  ;

instances, employees satisfied the annual training by successful '

completion of an examination (at least 75 percent correct) rather than actual classroom training. According to minutes from a May l 1996 Safety Review Board (SRB) meeting, the effectiveness of the aforementioned approach to training was under review by the SRB.

However, training for new employees and visitors, involved i

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a 5 I attendance at General Employee training (GET). The inspector ,

attended the GET and noted that training included a discussion  !

regarding radiation protection, pregnant workers, ex)osure lin its, women declaring pregnancy, and site warning /accounta)ility procedures. In addition, the inspector reviewed the Training Instructor's guides or outlines entitled Radiation Workers Training, Nuclear Criticality Training, Controlled Area Access Training, and respective tests for adequacy. For verification that training was current and up to date, eight names were randomly  !

selected from the SERF 4 personnel monitoring air sampling program. No problems were noted.

The inspector also reviewed the quarterly ALARA Committee meeting minutes for 1996. The licensee *s SRB functioned as the ALARA Committee. The meetings were held on April 17 May 30, and September 19, 1996. The fourth quarter meeting was delayed due to the fuel assembly incident. The inspector noted that aapropriate representation from the facility's Health and Safety, SERF, Manufacturing, Facilities, QC/QA, and Material Inventory departments had been established. However, there was some concern during the middle of 1996 with respect to meeting attendance and participation. The inspector also noted good ALARA '

recommendations such as develo)ing a more permanent measure of ALARA performance to kee) tracc of exposures and the rotation of individuals through the )LR to increase and maintain an awareness of the radiological conditions in the area. However, there was no apparent formal endorsement of the ALARA recommendations by the committee. The inspector discussed this issue with the licensee, including the evaluation of the ALARA recommendations by the SRB, a plan for implementation or rejection, and a formalized tracking system that would assign the recommendation to an individual with a due date for closure. The licensee discussed the use of an existing tracking (Quality Assurance Report (QAR)) system for this purpose.

c. Conclusions The above training appeared to provide a minimally acceptable level of training to employees regarding radiation protection and ALARA concepts in minimizing the exposure to radioactive material.

The training documentation (attendance sheet and/or exam) for randomly selected employees were reviewed and all training was current and up to date. The ap)arent lack of a program for the formal review and tracking of A_ ARA recommendations was noted as  ;

an area for improvement.

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6. Management Oversight of Program (R1.11)

a. Inspection Scope Chapter 2.0, Section 2.7 of the license specified that independent audits be conducted in accordance with written instructions or procedures. Procedure AS 1125, Health Safety Audits, Revision (Rev.) 14, dated September 14,1995, 3rovided a description of the audits performed at Framatone Cogema ruels (FCF) to maintain nuclear, industrial, and radiological safety parameters within i acceptable limits. The inspector reviewed the adequacy of I management controls for ensuring program compliance with the l regulations and license requirements. I

b. Observations and Findinas The inspector reviewed the semi annual audit dated March 21, 1996 and the previous audit dated December 14, 1995. An inde>endent audit for the second half of calendar year 1996 had not )een performed at the time of the inspection, but was scheduled for January 22, 1997. The inspector determined that the aforementioned date would meet the frequency for semi annual, as defined by the licensee's procedures to be six (6) calendar months l plus 25 percent (45 days). One aspect of the inde)endent audits i discussed by the inspector involved the scope of t1e semi annual  ;

reviews. According to documentation reviewed by the inspector, i seven (7) audits were performed during the period of June 1993 to '

present. The audits were conducted semi-annually as required by i procedures. However, the scope of the audits was extremely limited. That is, the audits usually were limited to only one  ;

element of the radiation protection program-(e.g., personnel i monitoring program) and resulted in a total of two programmatic  !

elements reviewed during the entire CY. Within those specific  !

areas audited, the review was comprehensive. The inspector i expressed concern regarding the audit scope to provide a timely program review. In response, the licensee indicated that the upcoming audit would include an expanded scope. The inspector  !

informed the licensee that the independent audit scheduled for January 22, 1997, would be tracked as an inspector followup item )

(IFI) (IFI 70 1201/97 01 01).

In addition, the inspector reviewed the licensee's radiological deficiency reporting (RDR) system, with an emphasis on the quality of the corrective actions and periodic assessments of the trends identified in the RDRs. The licensee made an assessment of the RDRs for 1995, however, the assessment for 1996 RDRs had not been i comaleted at the time of this ins)ection. In 1995, a significant num)er of RDRs pertained to poor lealth physics practices, including improper wearing of lapel air samplers, and lapel samples exceeding the four Derived Air Concentration / hour (DAC-hr) action limit. The inspector noted that the present categories for RDRs made it difficult to trend certain problem areas.

7 The inspector also noted that in all cases, the section pertaining to the action (s) to prevent recurrence on Form RP-014 1, Rev. A, was completed by the health physicist. The ins)ector discussed this aaproach with the licensee and indicated t1at this action could )e completed by the responsible area supervisor with a s)ecified time limit to respond. This method would result in s1aring the responsibilty to resolve problems that are self-identified and the develo) ment of solutions. If there is no response received, then t1e request for corrective action may be elevated to the next level of management. The responses should be reviewed by the health physics staff with the closure action sent back to the appropriate supervisor. Any "open" RDRs could be tracked so closure status can be managed. The licensee acknowledged the inspector's comments.

c. Conclusions The independent audits were effective in the identification of areas warranting attention. However, the scope of the audits was limited and did not appear to provide a timely program review. In addition, an area for im)rovement was noted pertaining to the reassignment of responsiJility to develop corrective actions in response to a radiological deficiency.

B. Environmental Protection (88045) (R2)

1. Monitoring Program Results (R2.02)

a. Inspection Scope The inspector reviewed selected aspects of the environmental monitoring and sampling program to ensure that the commitments in Section 5.2 of the license application were met. Section 5.2 of the License Application specified the requirements for the environmental monitoring program. Section 5.2 also specified that environmental monitoring shall be conducted in accordance with approved procedures which requires the environmental data to be evaluated against internal action levels.

b. Observations and Findinas The inspector reviewed and discussed selected environmental sample results collected and analyzed in 1996, including direct radiation monitoring using TLDs, environmental air particulate samples, vegetation, fish, surface water, sediment, and soil samples.

For the selected data reviewed, sample matrices were collected and analyzed in accordance with procedural requirements. The inspector noted that water, soil, sediment, and vegetation samples were collected annually as specified in the license application.

Twenty three samples were collected in October 1996 and analyzed for gross alpha and beta activity by the licensee's contract

8 laboratory. Seventeen out of the 23 samples indicated concentrations of alpha and/or beta activity in excess of the administrative action level of 20 pC1/ gram specified in procedure RP 011. Since the last inspection, the inspector noted an improvement in the licensee's timeliness for reviewing environmental data which was evaluated against internal action levels. After a review of the data, the licensee requested the contract laboratory to re analyze the samples with a longer count time. The second analysis results were received by the licensee on January 15, 1997. The inspector noted that ten samples exceeded the action level of 20 pCi/ gram with a range from 20.8 pCi/ gram to 56.0 pCi/ gram for gross alpha and 21.0 to 28.9 pCi/ gram for gross beta. The maximum concentration was a

, soil sample collected from the wet weather stream. This area was currently under review by NRC/NHSS for unrestricted release.

Excluding the soil samples collected in the vicinity of the wet weather stream, there were no soil samples that exceeded the gross alpha action limit, however, the following samples exceeded the gross beta action limit: (1) sediment (21 pC1/ gram): (2) soil (28.9 pC1/ gram): and (3) three vegetation samples (22.4 -

l 28.3 pC1/ gram). At the time of this inspection, the licensee was in the process of determining the next course of action, including the re-sampling of the affected areas. The inspector discussed performing isotopic analyses to determine if the activity was from licensed material.

, c. Conclusions

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The inspector concluded that the licensee's sampling program was consistent with the requirements in Section 5.2 of the license application and licensee procedures. Management oversight in the area of environmental monitoring data review had imsved since the last inspection. The licensee faces a challenge to determine the source of the anomalies noted in the soil, sediment, and vegetation sample results collected in 1996.

2. Quality Control of Analytical Measurements (R2.04)

a. Insoection Scoce The inspector reviewed the licensee's quality control 3rogram for environmental analytical measurements to verify that t1e licensee had maintained adequate management controls for the environmental program.

b. Observations and Findinas The licensee primarily relies on the use of a contract laboratory to perform analyses of the various environmental samples collected throughout the year. The only samples analyzed onsite are the perimeter air samples which are collected weekly and analyzed for gross alpha and beta radioactivity.

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9 i During the review process, the inspector noted that the licensee had no formal procedure specifying the quality assurance (QA) and quality control (QC) program for environmental sample results.

i Specifically, there was no guidance for the evaluation of quality control data, interlaboratory and intralaboratory comparisons, audits of the primary contractor laboratory, spike sample program, and crosscheck sample program. The inspector discussed the use of existing programs for QA such as United States De)artment of Energy's (USD0E's) Quality Assessment Program (QA)). In this

)rogram, environmental sam)1es were prepared by the Environmental 1easurements Laboratory (E1L), USDOE, in New York. The QAP provided an external assessment of environmental radiological analyses. In addition, there was no apparent procedural guidance on performing periodic audits or assessments of the licensee's -  ;

environmental monitoring program's primary contract laboratory.

c. Conclusions t

The licensee's quality control program for environmental j analytical measurements was less than adequate in that there was l no formalized procedure to provide guidance for implementing a quality assurance program. In addition, there was no evidence that the licensee had implemented a program to evaluate the performance of its contract laboratory.

C. Waste Management (84850 and 88035) (R3)

1. Airborne Effluent Controls, Procedures, and Instrumentation (R3.03)

a. Insoection ScoDe The inspector reviewed the licensee's airborne effluent procedures and controls to verify that systems and programs were in ) lace to {

assure compliance with applicable license conditions and rederal j regulations. i 10 CFR Part 20 requires radioactive releases to be within certain limits and ALARA. Safety Condition S 1 of SNM 1168 required the

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licensee to use licensed material in accordance with the statements, representations, and conditions of Part I of the License Application dated June 22, 1990, and supplements thereto.  :'

Sections 3.2.2 and 5.1.1 of the License Application specified the requirements for gaseous effluent controls,

b. Observations and Findinas I The inspector examined the licensee's program for sampling the gaseous effluent release points at the facility, as specified in 3 RP 004, Airborne Radioactivity, Rev. 7, dated October 10, 1995.

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Included in the examination was a selected review of applicable records for the third and fourth quarters of 1996. The inspector l noted that the licensee discharged gaseous effluents from.four i l

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10 release points: (1) Main Stack (the PLR area and SERF 1 controlled area): (2) SERF 2 radiologically controlled area; (3) SERF-3 radiologically controlled area, and (4) SERF 4 radiologically controlled area. The inspector verified that the controlled area effluents were continuously sampled for gross alpha and beta airborne radioactivity when the facilities were in an operational status and that samples were collected on a daily basis, except weekends and holidays, i

The inspector also reviewed RP 004, Airborne Radioactivity, and noted an incorrect reference to 10 CFR 20.403 in Step 13.5. The appropriate references should be 10 CFR 20.2202 and/or 20.2203.

In addition, the inspector noted that Step 9.5 of the procedure was incomplete in that there was no guidance as to what to do if the face velocity of an air capture device or containment hood was outside of the specified range. The inspector noted from a review of the face velocity data records for the last quarter for 1996 that several hoods were greater than the maximum specified face velocity indicated on Form RP-004-5. The inspector did not nor.e any significant affect on the air flow balances of shared systems that would cause the face velocity to be less than the minimum s)ecified on Form RP 004-5. The inspector discussed this caservation with licensee representatives and RP 004 was revised to provide guidance to the technicians performing the face velocity measurements to notify the health physics staff when an air flow measurement is out of range.

The inspector also reviewed AS 1115. Regulatory Requirements for License Changes and Incident Reporting, Rev. O. September 21, 1996 and noted that Exhibit A, Summary of Reporting Requirements for Radiological Events, lacked the following pieces of information:

e Appropriate telephone numbers to the NRC Operations Center and facsimile number to the Regional Administrator as indicated in 10 CFR 20.2202(d)(2).

e The 24-hour notification requirement should be saecified in

" block / row 2" of Exhibit A as indicated in 10 CF1 20.2202(b).

e The theft or loss of licensed material should be addressed in the Exhibit.

In addition the inspector reviewed procedure RP 014 Reporting of Radiological Deficiencies. Rev.1. June 25,1993 and noted the following inconsistencies in the guidance provided in Exhibit C:

e The Exhibit did not provide guidance on how to handle the theft or loss of licensed material.

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l e The telephone number listed in the Exhibit as 301 951 0550

was intended to be used for reporting the loss or theft of licensed material and not for.other required notifications as indicated in the Exhibit. The teleahone number for i making notifications required by 10 CF120.2202(a) and (b) i is 301 816 5100.

l e Step 3.4.2 of Exhibit C specified the incorrect Zip Code for ,

the USNRC Region II Office. The correct Zip Code is 30323. l The inspector also noted that Step 7.2.6 of RP 014 did not list as I examples of abnormal occurrences the following: anomalous  !

environmental sample results; lost environmental samples; elevated l stack sample results; missed sample collections; etc. i

c. Conclusions l The licensee had implemented an effective program to monitor and control gaseous radioactive effluents. There were a number of  !

inconsistencies noted in the )rocedures pertaining to i notifications and re>orting w11ch may indicate that a more l detailed review of t1e procedures by the licensee is warranted. l Although there was some lack of guidance with regard to handling ,

out of range measurements in an air flow surveillance procedure, I the licensee's prompt response to resolve the deficiency was acceptable.

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2. Liquid and Airborne Effluent Monitoring Results (R3.02 and R3.04)

a. Insoection Scooe  !

The inspector reviewed the licensee's airborne effluent monitoring l results to determine if the gross alpha radioactivity in the j effluent was below the license application limit of 10 microCuries per quarter (yC1/ quarter) as specified in Section 3.2.2.1. The ins >ector also reviewed the liquid effluent monitoring results wit 1 respect to the limits referenced in Section 5.1.2 of the license application.

b. Observations and Findinas The inspector reviewed the licensee's quarterly effluent air sample reports for the third and fourth quarters 1996 and verified that the airborne releases were well within the 10 yCi/cuarter release limit for gross alpha radioactivity as specifiec in the license ap)lication and RP 004 Airborne Radioactivity, Rev. 7, l dated Octo)er 10, 1995. The third and fourth quarter gross alpha I results were 3.1 gCi/ quarter and 2.8 pCi/ quarter, respectively.

For the same time periods, the gross beta results were 18.5 gCi/ quarter for both quarters. The source of the beta activity was primarily from Co 60 due to other licensed activities in four Service Equipment Refurbishment Facilities (SERFS).

12 The inspector also reviewed the licensee's liquid effluent controls and monitoring results. The liquid effluent controls <

were specified in procedure AS 1104, Waste Water Effluent Control, '

Rev. 18, September 23, 1996.

1 Potentially contaminated liquid waste releases via a dedicated drain line to the wet weather stream were ceased on December 1, 1987. After December 1,1987, all radiologically contaminated water generated by operations was rerouted to a dedicated evaporation system with the offgas being discharged through the plant high efficiency gaseous filtration system. The licensee had a Retention Tank System that was used for non-contact (non- J radioactive) industrial waste water. Licuid discharges from the Retention Tank System were sus > ended in June 1993. Subsequently, the Retention Tank System had >een removed, thus precluding any

, liquid effluent discharges via this pathway. Radiological releases via the liquid pathway would occur only during spills or other non routine events.

There were four liquid waste streams identified: (1) sanitary waste water: (2) industrial waste water: (3) noncontact cooling water: and (4) storm water run off. Sanitary waste water was '

piaed underground directly to the waste treatment facility at NN D. The industrial waste water was treated via the ion exchange  !

system and discharged to the Lynchburg Regional Waste Water Treatment Facility. The noncontact cooling water was discharged to the plant fire pond and released to receiving waters (outfall 1). Storm water run off was also discharged to the fire pond via a series of storm drains. The licensee verifies that plant processes do not contaminate these pathways by collecting one liter grab samples from outfall location #1. This liquid effluent sample was required by the licensee's National Pollution Discharge and Elimination System (NPDES) permit. Section 5.1.2 of the license application also specifies the requirements for the collection of various surface water samples. The inspector reviewed the grab sample results collected from outfall location

1. 1 on December 12, 1996. Although the total uranium concentration was less than 0.4 parts per billion (ppb) which was also less than the NPDES limit, U-234 was detected at a concentration which indicated an apparent presence of high enriched uranium (HEU). At the time of this inspection, the licensee was in the process of re sampling the outfall for another analysis to confirm the results.

c. Conclusions The licensee had implemented an effective program to monitor and control gaseous radioactive effluents and to maintain the radioactivity releas d in those effluents to quantities less than the license application limit and concentrations which were below the limits specified in 10 CFR 20 for release of radioactive

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at outfall location #1 at a concentration which may indicate the presence of HEU.

3. Waste Shipping (R3.08) and Tracking of Waste Shipments (R3.09)

a. Insoection Scope l The inspector reviewed and discussed with licensee representatives activities associated with the storage of low-level radioactive waste (LLRW) generated from onsite operations and its transfer to ,

a licensed waste processor for disposal. Specifically, the i inspector reviewed the licensee's program as it pertained to the requirements of 10 CFR 20.2006 and Appendix F to 10 CFR Part 20.

b. Observations and Findinas  !

The inspector toured and examined the licensee's storage areas for  !

LLRW and noted that the licensee maintained two storage locations for LLRW. The licensee temporarily stored all LLRW generated from the SERF and fuel handling areas into a dedicated SeaVan container for each facility. The solid waste consisted primarily of packaging material, floor sweepings, filters, decontamination materials, contaminated equipment, and evaporator sludge. Once the SeaVan containers were filled, the licensee shipped the containers to a licensed waste processor for sorting and compaction before the waste was buried at a licensed disposal facility.

The inspector reviewed selected sections of Radiation Protection Procedure, RP 007, " Shipment and Receipt of Radioactive 4 Materials," Rev. 4. January 10, 1997, and noted that a system had been established to verify that acknowledgement of receipt of the manifest from the waste processor had been received and that procedures were in place to effect an investigation in any instances wherein acknowledgement of receipt of the shipment had not been received within the time period specified 1r.10 CFR 20.

Appendix F. A review of two of the licensee's shipping records for waste shipments made to a waste processor since November 1996, indicated that the licensee had received from the processor a signed copy of the shipping papers.

The inspector reviewed manifest records of two shipments of radioactive waste made since the last inspection (96 111 4 and 96-107-4). Both of these waste shipments involved the transfer of radioactive materials to a licensed waste processor for treatment and repackaging. The manifests were complete and met the applicable requirements of the regulation specified in Appendix F to 10 CFR Part 20.

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c. Conclusions The inspector concluded that the licensee's controls and procedures for the solid waste management program were acceptable and capable of accomplishing its safety objectives.

III. General A. Followup on Previously Identified Enforcement Issues and IFIs (92702, 92701) (G1)

, 1. VIO: 70-1201/95-03 01 (EEI)

a. Summary of Concern Failure of the QA program to assure that the UNC 2901 (BW 2901) shipping containers manufactured by the licensee during 1983 were built in accordance with the established criteria (manufacturing drawings).

b. Observations and Findinus 4

The inspector reviewed the licensee's responses dated February 23, 1996 and May 15, 1996 and the NRC letter dated April 29, 1996.

Basically, the licensee performed a 100 % inspection on all the UNC 2901 (BW 2901) shipping containers. This was completed between May and June 1995. The Certificate of Compliance (CoC) drawings were subsequently revised to bound the inspection results 4

and were submitted to the NRC for approval on February 29, 1996. '

The NRC approved the drawing changes to reflect borated aluminum plate dimensional changes on March 21, 1996. A meeting was held on April 19, 1996 between the licensee and NRC/NMSS/SFP0 in Rockville, MD to discuss the Model No. DHTF transport package (NRC CoC No. 9203). The licensee presented a proposal to submit an application for amendment of the CoC to accommodate the following changes:

1. To increase the uranium enrichment from 4.1 weight percent to 5.0 weight percent.

2. To authorize transport of annular fuel pellets.

3. To revise the packaging drawings to better identify package 4

features, dimensions, or materials of construction, that are important to the performance and safety of the package.

The licensee submitted an amendment request on May 31, 1996, with

supplements dated August 15 and September 9 and 10,1996. The NRC 4

approved the amendment request on September 11, 1996.

15 On future packaging fabrications, the licensee indicated that it will perform inspections using the licensed drawings in addition to the manufacturing drawings.

c. Conclusion After reviewing the corrective actions artaining to the concern noted above, the inspector determined t1at this violation will be closed.

2. IFI: 70 1201/96 03-01

a. Summary of Issue Establish a contract with a suitable vendor who can perform urine sample analysis or resolve the spike sample criterion for samples sent to the existing contractor,

b. Observations and Findinas The inspector reviewed this item and verified that the licensee had established a contract with a new vendor to perform radiochemical analyses of urine, feces, and fish samples (for the environmental monitoring program). The contract was effective until December 31, 1998.

'Before the contract was established, the licensee made site visits to three potential vendor laboratories from October 23 25, 1996.

During the site visits', the licensee reviewed the vendors' facility, e of custody,quipment, QC and QA data management, andprograms, procedures, staff qualifications. sample chain Although the licensee reviewed the selected vendor's QA/QC program, the results of the vendor's participation in an independent QA performance program (blind spike samples) were not available for the inspector to review. The inspector indicated to the licensee that these data should be available for review during subsequent inspections.

c. Conclusion This item will be closed since the licensee established a contract with a vendor ca3able of performing bioassay analyses. However, the results of t1e vendor's participation in a QA performance program should be available for review during future inspections.

IV. Manaaement Meetinas A. Exit Interview (M1)

The inspection scope and results were summarized on January 17, 1997, with those persons indicated in the Attachment. The inspector described the areas examined and discussed the inspection results, including the

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16 IFI and the likely informational content of the inspection report with regard to documents and/or processes reviewed during the inspection.

Although proprietary documents and processes were occasionally reviewed during this inspection, the proprietary nature of these documents or  ;

processes has been deleted from this report. Dissenting comments were  !

not received from the licensee.

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ATTACHMENT

1. PERSONS CONTACTED Licensee Personnel I

• T. Allsep, Health Physicist

• C. Armontrout Lead Auditor Quality Audits and Program

• C. Carr, Vice President, Manufacturing and Services

• G. Elliott, Manager, Safety and Licensing

• D. Gordon, Sr. Health Physicist

, *G. Lindsey, Health Physicist G. Mapp, Training Instructor Other licensee employees contacted included engineers, technicians, security, and office personnel.

• Denotes those present at the exit meeting on January 17, 1997

2. INSPECTION PROCEDURES USED IF 83822 Radiation Protection IP 84850 Radioactive Waste Management IP 88035 Radioactive Waste Management IP 88045 Environmental Protection IP 92701 Followup IP 92702 Followup on Corrective Actions for Violations and Deviations

3. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Description  !

l 70 1201/97 01-01 Open IFI - Review the scow and details of the I independent audit scleduled for January 22, 1997 (Reference R1.11).

70 1201/95 03 01 Closed VIO - (EEI) Failure of the OA program to assure that the UNC 2901 (BW 2901) shipping containers manufactured by the licensee during 1983 were built in I accordance with the established criteria

! (manufacturing drawings).

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18 70 1201/96 03-01 Closed IFI Establish a contract with a suitable vendor who can perform urine sample -

analysis or resolve the spike sample l criterion for samples sent to the existing contractor.

4. LIST OF ACRONYMS ALARA As Low as is Reasonably Achievable  !

CDE Committed Dose Equivalent '

! CEDE Committed Effective Dose Equivalent j l CFR Code of Federal Regulations ,

l CoC Certificate of Compliance j

! CY Calendar Year DAC Derived Air Concentration DDE Deep Dose Equivalent EML Environmental Measurements Laboratory .

FCF Framatone Cogema Fuels l GET General Em)loyee Training HEU high enricled uranium IFI Inspector Followup Item l LDE Lens Dose Equivalent l LLRW Low Level Radioactive Waste mrem Hillirem NMSS Nuclear Material Safety and Safeguards l NPDES National Pollution Discharge and Elimination System NRC Nuclear Regulatory Commission i' fi picoCuries

, )LR Pellet Loading Room ppb Parts per Billion QA Quality Assurance QAP Quality Assessment Program QAR Quality Assurance Report QC Quality Control

. RCA Radiation Controlled Area i RDR Radiological Deficiency Report Rev. Revision SRB Safety Review Board SERF Service Equipment Refurbishment Facility SFP0 Spent Fuel Project Office SRD Self-Reading Pocket Dosimetry TEDE Total Effective Dose Equivalent  !

l TLD Thermoluminescent Dosimeter  !

l yCi microCuries i l USD0E United States Department of Energy U 234 uranium 234

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